L'Oréal - 2018 Registration Document

Corporate Governance RISK FACTORS AND CONTROL ENVIRONMENT

fire safety training, first aid, pollution prevention, • recycling, general EHS awareness raising, etc. Function EHS training refers to training specific to a given business area or activity (for example, all of the packaging staff of a plant). Specific EHS training refers to EHS training for a particular workstation and the activities carried out by the employee. With respect to ergonomics, a “manual handling” e-learning course is provided to all employees. Lastly, a high level of expertise for global EHS Teams and the development of a “Top managers” EHS culture for managers and supervisors is assured via the deployment of training specific to each person. Monitoring compliance with the Plan 2.8.4.3.2. Hierarchy of risks of non-compliance with the 1. applicable rules (risk mapping) With respect to the Subsidiaries, the risk mapping of non-compliance with the Applicable Rules was created taking into account the type of activity (administrative, manufacturing, warehousing, etc.) and, thereafter, the type of Site (administrative offices, plants, distribution centres, research centres, etc.). With respect to the Suppliers, the risk mapping of non-compliance with the Applicable Rules was created for human rights, fundamental freedoms, the environment, health and safety, based on a methodology which takes two parameters into account: the vulnerability of the country (country classified at risk s according to the Verisk Maplecroft consulting firm) in terms of human rights and fundamental freedoms as well as the environment, health and safety and; the suppliers’ industry. s Country classification is based on indicators established by Verisk Maplecroft and is updated on a regular basis. The risk mapping provides a ranking of the controls implemented to ensure the correct implementation of the Applicable Rules and, in particular, enables the initiation of audits carried out by specialist third-party companies. The result of this risk mapping is presented in matrices used to decide when to initiate an audit.

With respect to Suppliers, in addition to the communication of the Applicable Rules via the Ethical Commitment Letter, an Internet site has been provided to strategic Suppliers (Class A Suppliers as defined in section 2.8.4.3.2) of raw materials and packaging and subcontractors for finished products. The site contains the following documents: Code of Ethics; and • L’Oréal’s policy on Suppliers/subcontractors and child • labour. Training A specific, compulsory e-learning course on ethics covering human rights and fundamental freedoms issues. In addition, new buyers receive compulsory training on Responsible Purchasing to learn about compliance with the Group’s Ethical Principles. An e-learning course on Supplier audits, detailing the applicable audit procedure, is also available for all buyers. A Suppliers version is available on the same website as the above information. There is also an e-learning course available: “ Ethics e-learning for business partners ”. Health, Safety and the Environment (EHS) (ii) Communication EHS managers are informed of the Applicable Rules by their line manager. Every Group Site must hold a day dedicated to EHS, once a year, to raise the awareness among all employees about the risks to which they are exposed and suitable prevention methods, in addition to specific local actions. In addition, a Group awareness-raising campaign about major safety risks, deployed over three years, and the implementation of a specific topic every four months, serve to develop employee awareness of risks over time. A monthly newsletter for the Group’s EHS managers and their team leaders enables performance tracking and the sharing of best EHS practices. Training EHS training includes the various training actions for health, safety and the environment and covers general EHS training, business line EHS training and specific EHS training. Training involves all L’Oréal employees, as well as temporary workers and subcontractors working in Group entities. General EHS training includes: core general training when a new employee arrives at a • Site (L’Oréal employee or temporary staff) regardless of their position;

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SUBSIDIARY AUDIT MATRIX

Type of country

Sites audited

All countries

Plants and distribution centres

REGISTRATION DOCUMENT / L'ORÉAL 2018

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